Introduction

Türkiye’s Artificial Intelligence Action Plan (“Action Plan”), published by the Ministry of Industry and Technology through the General Directorate of National Technology and Artificial Intelligence and covering the 2026-2030 period, sets out a roadmap for strengthening Türkiye’s artificial intelligence (“AI”) ecosystem and positioning the country as a regional hub for AI investment, technology and talent. The Action Plan adopts a broad ecosystem-based approach, addressing not only AI applications and models, but also computing infrastructure, data, energy, financing, human resources and the regulatory and ethical framework.

The Plan is designed as a policy and implementation framework rather than a self-executing regulatory instrument. Its glossary expressly states that concepts requiring legal binding effect will be separately defined through future legislative and secondary regulatory work. Nevertheless, the Plan is commercially material because it signals the direction of public investment, procurement, incentive design, infrastructure planning, compliance expectations and prospective artificial intelligence regulation.

The Four Pillars of Türkiye’s AI Strategy

The Action Plan is built around four interconnected pillars: Recognise, Utilise, Produce and Govern. Each pillar contains four actions, giving 16 priority actions in total, which the Plan maps against five core layers (energy, computing hardware, infrastructure, models and data, and applications) and cross-cutting components covering talent, financing, and regulation and trust. Together, these pillars cover the full AI ecosystem, from developing talent and data infrastructure to building computing capacity, supporting AI businesses and attracting international investment.

• Recognise, focuses on creating the foundations for a sustainable AI ecosystem. The Action Plan prioritises AI literacy, the development of qualified talent, stronger data infrastructure and a predictable legal and ethical framework. Türkiye aims to train 10,000 advanced AI specialists and 100,000 AI application professionals. The Plan also states that the national legal and ethical AI framework will be based on a proportionate risk approach that takes account of the European Union’s approach, with graduated obligations defined by risk level and simplified controls for low-risk applications.
• Utilise, moves the focus from capacity-building to practical adoption. The Government plans to expand access to high-performance computing and GPU infrastructure, establish a national computing strategy and launch the GPU for Everyone programme, particularly for researchers, start-ups and SMEs. Public procurement is also expected to be used to stimulate demand for AI solutions. One of the Plan’s most significant infrastructure targets is reaching 1 GW of data-centre capacity.
• Produce, aims to strengthen Türkiye’s position as a producer of AI technologies rather than solely a user of AI solutions. The Plan proposes AI Growth Zones, Regional Centres of Excellence and dedicated financing mechanisms, while also supporting the development of sector-specific foundation models and domestic capabilities in physical AI and robotics. AI Growth Zones are intended to offer investors access to prepared infrastructure, including energy, land and redundant high-capacity fibre connectivity, together with accelerated permitting and licensing processes, and to host multi-tenant AI Factories combining large-scale computing capacity with data spaces, model development tools, test environments and productisation services. The Plan targets the declaration of the first zone and the selection of anchor investors within 12 months, at least one zone operating at first-phase capacity by the end of 2027, and at least five zones declared and three operating by the end of 2028, alongside at least three Regional Centres of Excellence and six access points.
• Govern, addresses Türkiye’s international positioning and the governance of the AI ecosystem. The Action Plan aims to attract international AI and cloud investments, strengthen international cooperation and contribute to international AI standards and governance mechanisms.

Targets for the Action Plan Period

The Action Plan sets ambitious quantitative targets for the development of Türkiye’s AI ecosystem. These include:

• Training 10,000 advanced AI specialists and 100,000 AI application professionals, and introducing a foundational AI course at at least 50 universities by the end of 2027;
• Reaching at least 1 GW of installed AI and data-centre capacity by 2030, together with an annual low-carbon electricity purchase agreement (PPA) volume of at least 10 TWh and at least 1 EB of total storage;
• Mobilising at least USD 10 billion in predominantly private-sector AI and data-centre investment by 2030, with the incentive framework provided by the Data Centre and AI calls announced under the HIT-30 High Technology Investment Programme;
• Establishing dedicated AI financing mechanisms, comprising a National AI Research Fund of at least TRY 10 billion and an AI Growth Fund of TRY 15 billion; and
• Supporting at least 20 AI ventures through Series A/B or scaling investments, with at least two units of private capital mobilised for each unit of public funding.

The Action Plan also targets the establishment of regulatory sandboxes in at least five priority sectors, with at least one quarter of the projects graduating from those sandbox programmes to be scaled through licensing or public procurement within 12 months, and the development of sector-specific foundation models and domestic physical AI and robotics capabilities.

The implementation is designed to be phased:

• The 2026-2027 period is expected to focus on establishing the necessary institutional, regulatory and technical infrastructure, including governance structures, the piloting of data spaces, the clarification of investment processes for computing capacity and initial public-sector AI applications.
• The 2028-2030 period is intended to focus on scaling successful pilots, commercialising AI models and solutions, strengthening international partnerships and achieving the investment and infrastructure targets set out in the Action Plan.

A specific target for 2027 is to establish cooperation with international cloud companies through regional centres, capacity agreements or strategic partnerships in Türkiye. It further envisages reducing the preliminary eligibility and investment roadmap process for international investors using one-stop applications to a maximum of 30 business days.

Digital Sovereignty

One of the key policy concepts underlying the Action Plan is digital sovereignty. The objective is to ensure that Türkiye develops sufficient secure and resilient domestic computing capacity while remaining open to international cloud providers, technology companies and cross-border cooperation.

For this purpose, the Action Plan proposes a Computing Portfolio comprising public reserve capacity, domestic data centres and international cloud partnerships. This model is intended to diversify computing resources, improve scalability and resilience, and provide the domestic AI ecosystem with reliable access to computing capacity. Start-ups and SMEs are expected to benefit from dedicated access mechanisms, including the “GPU for Everyone” programme.

Digital sovereignty is particularly relevant for investors because the Action Plan links AI infrastructure policy with energy availability, low-carbon electricity, data-centre infrastructure, data protection, cross-border data transfers, cybersecurity, service continuity and intellectual property protection. The Action Plan therefore indicates that future AI infrastructure investments may need to be assessed not only from a commercial and technological perspective but also against data governance, security and resilience considerations.

Implementation Principles

The Plan identifies four principal implementation principles:

• The first is speed and clarity, meaning a limited number of high-impact priorities, short-term deliverables and measurable targets.
• The second is market orientation, operationalised through a “scan–pilot–scale” cycle. Under this approach, use cases are to be identified systematically, tested rapidly through pilot projects and scaled where demonstrable value is achieved.
• The third principle is trust and responsibility. The Plan supports a proportionate risk-based approach, transparency and independent assessment, with the objective of enabling safe scaling rather than creating unnecessary barriers to innovation.
• The fourth principle is phased implementation and prioritisation. Initial efforts are expected to focus on governance structures, data-sharing mechanisms, access to computing resources, public-sector pilots and a trustworthy artificial intelligence framework. Capital-intensive infrastructure, broader regional deployment and international model exports are expected to be scaled in later phases, subject to performance outcomes, technical readiness and available resources.

Priority Sectors

• Sectoral roadmaps: The Action Plan provides for the publication of sectoral roadmaps for healthcare, agriculture, defence and e-commerce, setting out data and regulatory requirements, priority use cases, success indicators and timelines. Annual targets are to be reviewed with the participation of public-sector, private-sector and academic representatives.
• High-sensitivity sectors: Data access, security and compliance requirements in high-sensitivity sectors such as healthcare and defence are to be defined under separate regimes. In priority sectors, companies and consortia selected through open calls and competitive evaluation are to be granted access to data, computing resources, test facilities, certification and export support under the National AI Champions Programme.
• Sectoral pilot programmes: Pilot applications are envisaged in healthcare, energy and manufacturing, together with measures to increase SME capacity. Public procurement criteria for AI and a roadmap for public institutions are also foreseen, and the Plan targets the piloting and scaling of at least five AI-supported citizen service applications.
• Autonomous driving and physical AI: The Plan provides for the development of the infrastructure, legislation and test environments supporting autonomous driving, and states that safety supervision, incident recording and reporting, the insurance and liability regime and data security conditions applicable to autonomous driving tests will be separately defined. Test facilities are to include smart factory test lines, agricultural robotics, disaster and search-and-rescue simulation sites, autonomous driving test tracks and edge computing hardware validation laboratories.

Opportunities and Advantages for Investors

The Plan presents opportunities for investors in artificial intelligence infrastructure, data centres, cloud services, high-performance computing, robotics and sector-specific models. It targets the mobilisation of at least USD 10 billion in predominantly private-sector investment for artificial intelligence and data-centre infrastructure by 2030, supported by an investment-attraction framework combining incentives, expedited permitting, energy and fibre access, talent availability and intellectual-property protection. The incentive backbone of this framework is provided by the Data Centre and AI calls announced under the HIT-30 High Technology Investment Programme.

International cloud companies and infrastructure investors may also benefit from packages linked to regional headquarters, cloud or edge regions, capacity agreements and strategic partnerships. A single-window investor interface is intended to complete preliminary eligibility assessments and investment roadmaps within thirty business days.

Opportunities and Advantages for Developers

Developers and technology providers may access public-sector pilots, sectoral programmes, GPU credits, data-access initiatives, testing environments and regulatory sandboxes. The “GPU for Everyone” programme targets flexible access to 10 million GPU-hours per year; in its first phase, capacity contracts with at least five accredited domestic data centres are to make at least 2 million GPU-hours of credit available annually to researchers, start-ups and SMEs, with at least 40 per cent reserved for techno-ventures and annual allocation rising to at least 20 million GPU-hours by the end of 2028. Successful public deployments may generate valuable commercial and export references through standardised procurement specifications, digital badges, case studies and performance metrics. Start-ups may also benefit from the Artificial Intelligence Financing Ladder, including a National Artificial Intelligence Research Fund and an Artificial Intelligence Growth Fund, with targets of at least TRY 10 billion in research funding, a TRY 15 billion Growth Fund and support for at least twenty artificial intelligence ventures.

The proposed common rules, testing methodologies and certification standards should also provide greater predictability for product development and market entry, particularly for systems used in higher-impact sectors. Developers of sector-specific foundation models may further benefit from export-ready packages covering security testing, legal compliance, performance evidence and environmental impact.

Governance and Next Steps

Türkiye’s Artificial Intelligence Action Plan reflects a transition from an approach primarily focused on AI adoption towards an integrated AI investment, production and governance ecosystem. Its objectives extend beyond software and AI applications to encompass data-centre infrastructure, computing capacity, energy, financing, human resources, sectoral transformation and regulatory governance.

For investors, AI infrastructure, data centres, energy, cloud services, AI Growth Zones and AI Factories are likely to be among the most significant areas of opportunity. For AI developers, computing access, financing, sector-specific foundation models, regulatory sandboxes, public procurement and export-oriented product development are expected to be particularly relevant.

At the same time, the Action Plan signals that AI development in Türkiye will increasingly be accompanied by requirements concerning risk management, data governance, cybersecurity, intellectual property, technical safety and accountability. Companies operating or considering investment in the Turkish AI market should therefore monitor the implementation of the Action Plan closely, particularly as its policy objectives are translated into concrete legislation, regulatory measures, investment programmes and incentive mechanisms.

This client alert is provided for general information purposes only and does not constitute legal advice. For further information, please contact your usual contact at MARIF Law Firm.

The full text of the Action Plan is available at this link.